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No, you're writing something that happens to resemble a small subset of the functionality of a filesystem.

Most importantly, you're not duplicating the effort for every filesystem that you want to support encryption for, and the code can largely remain fixed once mature.

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kernel developers are free to factor in common functionality, calling into it library style, without making it into an externally visible layer. IIRC fs encryption and case insensitivity are often done that way, and I think I'd count the page cache and bios as larger library-style components as well (as opposed to the VFS layer which is more in a framework style).

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